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Application: 6/30/15/101 Grid Ref. SS97012846 Applicant: Arqiva Ltd, c/o agent (Arqiva), Location: Haddon Hill Car Park, Haddon Hill, Skilgate, Somerset Proposal: Proposed installation of a 30m shared communications mast, ground based apparatus and ancillary development within a fenced compound. As per additional information 01.10.15 (Full)

Introduction The application site is located in the public car park at Haddon Hill, Skilgate, within the south-east corner of the National Park. The proposed site for the 30m lattice mast is in the south west corner of the car park. The Haddon Hill public car park has toilets, interpretation boards, a shelter and a grassy “picnic area” for visitors to the hill. Beech and birch trees are scattered across the grassy banks within the car park. The car park is relatively enclosed by scattered trees, but there are open views to the north towards Wimbleball reservoir. To the west of the car park is an area of former plantation which was largely clear felled in the early 2000’s in order to restore an area of heathland and provide south facing slopes for heath fritillary butterfly. A narrow belt of pine was left along the southern fringe of the hill and adjacent to the car park, in order to screen the car park, provide some shelter and protect the neighbour’s trees from wind-throw. To the south of the car park lies Frogwell Lodge and its associated holiday let. To the west of this house, within the garden, is a small wind turbine (approximately 13.6m). The property does not benefit from mains electricity. The house itself is approximately 150m from the proposed mast. The wider Haddon Hill is an area of 176 hectares of open moorland, partly owned by the National Park Authority (93ha). The moorland was purchased by Exmoor National Park Authority in 1980 in order to conserve and enhance the natural beauty and wildlife of the hill and to secure public access. The car park was purchased separately in 1987 (from South West Water). Haddon Hill is Open Access land and is very well used by the public. It is designated as Section 3 moorland and is also a Site of Special Scientific Interest and Special Area of Conservation. However, the car park, itself is outside the designated areas. The application proposes to erect a 30m telecommunications mast on a corner section of the car park with an incursion in to the adjoining bank to form the compound. Approximately 2-3 informal car parking spaces would be lost. The mast would be erected within a 2m high timber, close boarded fenced compound of dimensions of approximately 8.5m by 8.5m. The proposed mast is a triangular lattice structure. The base would be approximately 3m wide and this would taper to approximately 1.7m at the top. At the top, antenna and dishes are proposed. The antenna would add to the bulk of the top section of the mast and have a width of approximately 3.4m. The telecommunications mast requires an electricity supply. The applicants have worked with Western Power and it is intended to bring a supply from a connection in the valley to the south. This would be brought underground with the route passing through gate openings, under a track, and then into the corner of the car park area. It will be possible to

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avoid the root systems of the trees around the proposed compound. To the south of the compound is a young beech tree that will grow and mature in the years to come. To the west are the pine trees that have been retained to help screen the car park from the wider area. Details of the electricity supply have been included with the submission but this element of the proposal is permitted development and is not formally part of the application for consideration. The application is part of the Government’s Mobile Infrastructure Project. This is an initiative to provide mobile coverage to areas where there is no coverage from any of the four networks. The Project has focused on seeking to provide masts and the related coverage in those areas which address the most not spots and cover the highest number of premises. The masts all provide coverage from all four mobile phone networks. The Government has confirmed that the Project will cease at the end of March 2016 and that only proposals that have all consents in place by the end of October 2015 will be able to be part of the programme (dispensation has been given by DCMS for this proposal to be considered at the November Meeting). In the case of the present proposal the applicants have explained that they have looked at 13 alternative sites that may have had the potential to provide coverage to the wider area. Some of these were on lower land that would have required a taller mast than that required at Haddon; had difficulties with providing an electricity supply, and/or were considered to have an adverse landscape impact. Planning Officers requested that the applicants investigate whether Britannia’s Shield was an option. This is an area of elevated woodland to the east of Haddon and falls outside of the National Park. The applicants have explained that this has been investigated and discounted because it is within a plantation and the proposals would affect on-going workings of the plantation by sterilising a large part of it, this mast would require a more expensive and longer power route, and it would require a taller mast than that proposed at Haddon in order to clear the existing trees and to compensate for the growth of the trees in the future. With the Haddon Hill mast proposal, officers have asked why the mast cannot be lowered and still provide a satisfactory level of coverage. The applicants have investigated this option and responded with both an explanation and photographs from a hoist which was raised on the application site and was able to take photographs from various heights. Officers will show these photographs as part of the Committee presentation. The applicants have commented as follows: “The height of the mast is required due to a combination of two technical factors: first, the need to provide radio coverage to the not spots and, second, unobstructed line of sight links back to the Mobile Network Operator’s (MNOs) shared installation outside of Shillingford. Of these two factors, the radio coverage requirement is the most important constraint here as the trees nearby will affect signals, reducing the coverage footprint, and an allowance has to be made for tree growth over the planned 20 years the MNOs have committed to provide coverage from this site. To demonstrate this point I’ve included in the attached documents extracts from the panoramic photographic surveys taken at the time of our design visit. The first photograph shows the view at 29m a.g.l., i.e. the position of the antennas on the proposed mast. As you can see, this is a clear and unobstructed view thereby enabling the antennas to be positioned so that they can ‘see’ down the valley to the north and provide coverage as far as Brompton Regis and Withiel Florey. The

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second photograph shows the view at 24m a.g.l. (for a 25m high mast) where the upper sections of the trees are now visible and are likely to be an impediment to coverage, and the third photograph is taken at 19m a.g.l (for a 20m high mast) where the trees are now in full view and will impact significantly on coverage over the life of the base station. This important technical constraint is not best demonstrated by coverage simulation plots, as these would still show some coverage at reduced mast heights, which is why panoramic photographs are always taken to supplement them and provide the radio planner with an understanding of the presence of trees and buildings nearby in order to inform the required height of the antennas. For the avoidance of doubt, the trees are not a factor for the transmission dishes as these will be orientated in the opposite direction towards the south. While the focus of the Mobile Infrastructure Project (MIP) is on coverage to premises within the not spots, this is to provide the MNOs with a degree of economic surety, which is necessary if they are to hold onto the operational costs for a long period. In that sense, the number of premises cross subsidises the delivery of coverage, and the many associated benefits it provides, over a much wider area: for example, by providing coverage to local roads, to farmland or to public rights of way. The key benefits of mobile coverage for the wider local area includes the ability to contact the emergency or breakdown services, for the ambulance service to send and receive life-saving data ahead of their journey to the hospital, and the socio–economic benefits to tourists, farmers, local tradesmen, doctors, vets and others often on the move in rural areas. A secondary benefit of the MIP is that it may also extend coverage to partial not spots, i.e. to locations where some, but not all, MNOs currently provide a service.” The applicants have supplied a revised and larger scale plan showing the coverage that would be provided were the mast to be permitted and constructed. This will be shown as part of the Committee presentation and shows that the area is extensive covering Skilgate, Upton, Brompton Regis and extending within the National Park to the north as far as Withiel Florey. The papers explain that the coverage would address 63 not spots and cover 145 premises. Consultee Response SKILGATE PARISH COUNCIL: I write in my capacity as Chairman of the Skilgate Parish Meeting with respect to the proposed mobile mast at Haddon Hill Car Park. Skilgate is part-situated within the Park and, like many other small communities hereabouts, we enjoy very few public services and/or private amenities. Accordingly, communications technologies are of very considerable interest and benefit to us. We have a moderately good broadband service – no thanks to the Connecting Somerset & Devon initiative or BT, but provided by a small entrepreneur who lives locally. Despite having adequate broadband, we have almost no mobile phone coverage. I am sure you are well versed in the important benefits that mobile phone technology can offer rural communities, especially in emergencies but also in providing an alternative to sometimes unreliable landlines. My purpose in writing is simply to say how much Skilgate Parish Meeting supports the proposal for mobile coverage here. We have communicated our support to the project team as well as via our elected WSDC and SCC representatives. I hope that ENPA will

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lend its full support to this proposal thereby reducing the relative isolation of our community. I feel also obliged to raise the issue of the lack of mains electric power supply at Haddon Hill – and to Haddon Hill Lodge in particular – given that a power supply must be provided for the proposed mobile mast. It would be a great shame if the opportunity were missed to rectify this omission and to connect one of the very few remaining dwellings that are without mains electricity in this region. Again, this is an issue has been raised with our elected representatives. BROMPTON REGIS PARISH COUNCIL: Having held its monthly meeting on Wednesday 7th October, Brompton Regis Parish Council’s response to the Planning Application 6/30/15/101 is as follows: Brompton Regis Parish Council is obviously grateful to be included in the deliberations over this application since in this case it directly concerns the parish. The BRPC has no objection to the application now that the area to be covered has been significantly increased since the initial projections. However, they are only in support if the predictive coverage area is achieved. If not, they expect the ENP to take responsibility and either cause this to be rectified or the mast to be removed. UPTON PARISH COUNCIL: Whilst we appreciate the potential impact of the mast upon the Park landscape, Upton Parish Council are in favour of the construction of the mast, and support the application because the improved communications will be an important benefit for local businesses, residents and visitors alike. In addition it is an important safety asset enabling the reporting of accidents and illness; being particularly beneficial to isolated and lone workers. We are a remote community and with poor internet connection the ability for more effective communications will be a huge boost to the area, its businesses and may even help encourage further investment. We also consider the proposed site to be the most suitable because it seems to provide good coverage at the least detriment to the surrounding landscape and communities it will hopefully serve. Consequently we support the application. WEST SOMERSET COUNCIL: No comment received SCC - ENVIRONMENT DIRECTORATE: No highway objections. HEAD OF CONSERVATION AND ACCESS - ENPA: Please the full comments set out at Appendix 1 of this Report. WILDLIFE CONSERVATION OFFICER - ENPA: No ecological concerns LAND AGENT - ENPA: No comment received MET OFFICE - SAFEGUARDING: No objections. NATS (EN ROUTE) PLC: No safeguarding objection. MID DEVON DISTRICT COUNCIL: Have confirmed they wish to make no comments. NATURAL ENGLAND: No objections. ENVIRONMENT AGENCY SOUTH WEST: Wish to make no comments. SOUTH WEST WATER: No objections.

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SOUTH WEST LAKES TRUST: No comment received WESSEX WATER AUTHORITY: No comment received WESTERN POWER DISTRIBUTION: No comment received Public Response 55 individual properties have been notified of this planning application. This relates to all properties within 2km of the application site. Additionally 3 yellow site notices have been placed at key parts of the Haddon Hill site to highlight the application proposals to visitors. A set of laminated plans have been on displayed on the noticeboard adjoining the toilet building and at the application site itself. The application was the subject of a formal notice in the West Somerset Free Press. The owner of Frogwell Lodge has initially commented; 1. I have been discussing with Western Power the ability to provide electricity to Frogwell Lodge as part of the mast application. However, the cost is substantial because the applicants are insisting on a 3 phase connection. 2. If the Government consider that Broadband and mobile phones are an essential part of life then electricity must be more so connection to the grid should be paramount in your planning decisions. 3. The location of the mast so close to Frogwell Lodge would also have a detrimental effect on property valuation and despite the assurance of the agent there is the question of health issues, particularly as these masts have not been up for very long. Notwithstanding the issue of an electricity connection there is the issue of compensation. 4. When the Water Company were repairing the dam there was significant disruption to the area around Frogwell Lodge and the fence needed repairing, it is quite likely this will happen again. 5. I had intended to increase the height of my wind turbine as the trees around the property are between 10-15 metres and continue to grow and have reduced its effectiveness. I will apply to raise the height of the turbine if electricity is not brought to my property. 6. If planning permission is given I hope that it is conditional on the applicant providing the facility to connect to their electricity cable and without any charges. The owner of Frogwell Lodge has made the further comments: Further to previous correspondence I have been advised that should the application fail, it would be sensible to apply for planning permission to increase the height of my turbine to 18m - to take account of the growth in the trees surrounding the property over the last 14 yrs & future growth, as they are reducing the electricity my turbine is creating. If however the Mast is approved there is the possibility that I can remove the Turbine leaving only one mast on the hill.

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Of those in the community that feel the mast would detrimental, I am most affected but in the interest of obtaining mains electricity and thus coming into the 21st century I would support the application, particularly as it will also provide the area with better mobile and broadband connections, which are badly needed.

One letter of support setting out the following comments: I wish to register my support for this application as a local business, employing 16 people riding horses, who is currently without any mobile signal on the basis that it will be a great asset to be able to communicate in the event of any accident. It will allow me to communicate with my owners in regard to my business. I believe that this overrides the fact that the mast will be clearly visible from our premises.

Four letters of objection setting out the following objections; 1. The erection of the mast is proposed in the National Park. Haddon Hill is used and enjoyed by many and is in keeping with the surrounding area and this will be completely changed if the mast goes ahead. It is appreciated that mobile reception is important but this mast will be very harmful to this site and the moor itself. The mast in such a visible and well used site is not the answer. 2. The mast will blight the landscape in an area of natural beauty the character of which should not be spoiled. Such is the height of the mast that it will present an unacceptable intrusion for ever. The mast will have a detrimental visual impact not just in the immediate vicinity but also much further afield. It will be clearly visible from Dunkery Beacon and Winsford Hill. 3. The proposal may be illegal and in contravention of National Laws for the protection of National Parks and its ethos. I will be able to see the mast from my house and garden and it will look horrendous ruining a cracking view. 4. Insufficient regard has been given to alternative sites which would deliver equivalent coverage. Why cannot the antenna be put on the masts at Roborough Gate instead? The reasons for not pursuing Britannia’s Shield are not compelling or detailed. 5. The proposed site is used extensively by the local community and tourists for the quiet enjoyment of protected countryside. The mast will make a huge unavoidable impact on those wishing to enjoy Haddon Hill and will be visible not just in the immediate environs of the hill but for miles around. 6. People wishing to enjoy Haddon Hill will be the subject to a blizzard of electromagnetic radiation. There is still insufficient data to determine whether such radiation exposure presents a long term health hazard. 7. The Authority should reject this application in favour of a less intrusive site.

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THE EXMOOR SOCIETY has set out detailed objections to the application. Their comments are set out below: The Executive Committee of the Exmoor Society discussed this application at its most recent meeting and wishes to make the following comments. 1. The Society is disappointed that it was not invited, as a Consultee, to see the blow-up mast erected by the applicant which would have helped us have a better view of its the potential impact. In addition we are disappointed that the applicant has not been required to submit a full Landscape Impact Assessment as the references to the impact on the landscape in their application are inadequate. 2. It is the Society’s view that this mast, which should it be erected, will be one of the highest within the National Park will have a seriously damaging impact on the landscape and its enjoyment by the public. Its location falls within Section 3 Land defined as Moor and Heath in the Conservation Map 1989. To the north there are also extensive areas of Section 3 Woodland. The site is surrounded by land designated as Landscape Character Type D; Open Moorland, in the Exmoor Landscape Character Assessment document. This landscape type is defined as having a strong character, being very recognisable and is synonymous with Exmoor. Perhaps more so than any other landscape type. The Landscape Strategy for Open Moorland, agreed by the Authority, is to conserve and enhance its landscape character. The strategy goes on to state; ‘It is essential to conserve the open and simple visual character of the Open Moorland’, and continues; ‘there is a danger that further incremental inclusion of human elements in the landscape will threaten to reduce the remote and wild character’. Should the mast be erected it is contrary to the Authority’s own landscape strategy. 3. Visibility. At least the upper half of the mast will be visible from many locations, both in the Park and to the south of the Park. By definition it will be visible from all those areas that will receive a signal from the mast. The applicant’s own documentation shows this to be a vast area. The mast will be visible from the immediate vicinity which the Park’s own documentation confirms ‘is particularly popular with visitors and that the area is notably busier than other areas of moor’. The mast will also be visible from all those people who visit the Wimbleball Lake, a major tourist attraction. 4. Amelioration. Whilst there are a number of trees in the immediate vicinity of the mast though none of these is higher than half the height of the mast and some are lower. To the west there is a thin belt of conifers, at the most 3 to 4 trees wide. These trees were left after the clearance of Haddon Plantation. It is considered that they are likely to suffer from wind throw and cannot be considered a permanent screen. 5. The compound. The 8.3 x 8.3 m compound with its 2.2 m high wooden board fence is in itself not an attractive feature and one wonders whether this fence will be high enough to guarantee security. 6. Noise. The applicant confirms that there will need to be cooling fans, which it states will only operate in hot weather. How noisy they will be and whether there will there be any residual background ‘hum’ when the fans are not operating is not clear. 7. The Society welcomes the fact that the power supply to the compound will be undergrounded thereby reducing further damage to the landscape.

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Local Plan Policies It is the Society’s view that this application is contrary to a number of policies both in the existing Local Plan and the emerging Local Plan. In particular it is contrary to policy POLICY LNC1: Development proposals in the National Park will be expected to be compatible with the conservation or enhancement of the natural beauty, wildlife, and cultural heritage of Exmoor, and the public understanding and enjoyment of those qualities. It is contrary to policy POLICY LNC3 which states: Development proposals which adversely affect the natural beauty of areas shown on the Proposals Map as Section 3 Moor, Heath, Woodland, Cliff and Foreshore will not be permitted. Likewise the application is contrary to policy POLICY U11: Development proposals for telecommunication equipment, masts and other antennae essential for technical or operational reasons, will be permitted where there would be no unacceptable adverse effect on: 1. the natural beauty of the Exmoor landscape or 2. the amenity of nearby residents and visitors. Many of these policies are continued, if not strengthened, in the Publication Draft of the Developing Local Plan. For example under the section entitled ‘CONSERVING AND ENHANCING EXMOOR; Objective 2: sets out ‘To ensure that Exmoor’s moorlands remain open, remote and relatively wild in character; that views are preserved, and strategically important areas of former moor and heath are managed in a way that restores their wilder landscape character. A mast in this location conflicts with this objective. The introduction of the National Planning Policy Framework (NPPF) may be considered by some to have changed the emphasis of planning policies, but the NPPF goes on to make a clear that “great weight should be given to conserving landscape and scenic beauty in National Parks …, which have the highest status of protection in relation to landscape and scenic beauty. There is a balance to be struck between need and harm. Government guidance is clear that need alone is not the only factor to be considered. Objectively assessed needs should be met, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole, or specific policies in the Framework indicate development should be restricted. Finally and perhaps most important the Society is reminded of the first purpose of National Parks which is; ‘To Conserve and enhance the natural beauty, wildlife and cultural heritage (of the National Parks). The Authority undertakes, in its policies, to attach the greatest weight to this policy in the case of conflict. This application would seem to be an instance of such a conflict. The Society anticipates that the Authority’s members will take these statements of fact fully into account when making their decision.

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CPRE has raised Objections to the applications. Their comments are set out below; CPRE Somerset wishes to object to this application. Exmoor National Park’s own website proclaims on the planning pages that “The planning policies seek to ensure that development is of the right scale, directed to appropriate locations and conserves and enhances the character and appearance of the National Park. Development proposals should be of a high quality so that the special qualities of the National Park are maintained”. This proposal to site a 30m communications mast directly in a visitor car park forming part of the very popular, and visually prominent, Haddon Hill open access land cannot be compatible with this requirement and we find it hard to believe that an alternative site cannot be found. We recognise the conflict between the purposes of the National Park and the socio- economic importance of modern communications, even in protected areas such as National Parks. However, if this application is allowed it would, in our opinion, contravene the fundamental purpose of the National Park which, according to the Environment Act 1995, is to: 1. conserve and enhance the natural beauty, wildlife and cultural heritage 2. promote opportunities for the understanding and enjoyment of the special qualities of national parks by the public The Act goes on to state that when National Parks carry out these purposes they also have the duty to seek to foster the economic and social well-being of local communities within the National Park. There are many well established policy arguments that the two basic purposes of a National Park should take precedent over this duty. We appreciate that it is important to grasp opportunities to increase mobile coverage in the area but we do not accept that this is the only site available. If the mast was moved further east along the ridge and sited within the woodland of Britannia Shield, it would be further from the open access land of Haddon Hill so less visually intrusive, not in a car park where people come to enjoy the natural beauty of the National Park. Furthermore, this would place the mast outside the boundary of National Park. There has historically been a small wind turbine immediately to the south of the car park, which the owner of the property says he will reinstate. If so, the cumulative effect of adding the mast will be far greater than a mast or the turbine on its own and this must be considered when making a decision on this case. On a point of principle, we are dismayed to see that the applicants have not submitted a landscape assessment with their application and would suggest that any decision be delayed until a proper assessment is submitted. We understand that the land in question is actually owned by the National Park. If land with this level of designation that is actually in National Park ownership is not protected from unnecessary development, then is anywhere really safe?

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RELEVANT HISTORY 6/30/79/001 Construction of a car park and picnic area and the erection of toilets at Frogwell Lodge, Haddon Hill. Full Approved 11 October 1979 6/3/09/104 Change of use of hardstanding area to operational and the installation of a telemetry kiosk 1m high x 1.3m x 0.5m on concrete plinth 0.2m high x 0.15m x 0.15m. Full Approved 21 August 2009 MOST RELEVANT DEVELOPMENT PLAN POLICIES: National Park Purposes and the Duty are as follows: 1. Conserve and enhance the natural beauty, wildlife and cultural heritage

2. Promote opportunities for the understanding and enjoyment of the special qualities of national parks by the public When national parks carry out these purposes they also have the Duty to: Seek to foster the economic and social well-being of local communities within the national parks The key planning policies are detailed below. EXMOOR NATIONAL PARK LOCAL PLAN (2001-11) LNC1 General National Park Policy Development proposals in the National Park will be expected to be compatible with the conservation or enhancement of the natural beauty, wildlife, and cultural heritage of Exmoor, and the public understanding and enjoyment of those qualities. In considering applications the Authority will give the greatest weight to these purposes and in the case of a conflict greatest weight will be attached to the first purpose. Due regard will be had for the economic and social well-being of the local communities in the National Park. The application site itself is not within the land designated under Section 3 of the Wildlife and Countryside (Amendment Act) 1995. This likes to the north. Nevertheless Policy LNC3 may be considered relevant. Policy LNC3 states that “development proposals which adversely affect the natural beauty of areas shown on the Proposals Map as Section 3 Moor, Heath, Woodland, Cliff and Foreshore will not be permitted”. CBS12 New Development This policy contains a series of tests for new built development including that “all development should conserve and, respond to opportunities to enhance, the natural and built environment”. U11 Electricity and Telecommunication Development Development proposals for telecommunication equipment, masts and other antennae essential for technical or operational reasons, will be permitted where there would be no unacceptable adverse effect on: (i) the natural beauty of the Exmoor landscape or (ii) the amenity of nearby residents and visitors.

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The Authority will expect existing masts and other structures to be used wherever possible. Approvals will be subject to a condition requiring the removal of equipment and the reinstatement of the land when the equipment is no longer required. PUBLICATION DRAFT EXMOOR NATIONAL PARK LOCAL PLAN (2011-31) The Publication Draft Plan is not an adopted Plan but is a material consideration which needs to be considered in the planning decision making process. Paragraph 2016 of the National Planning Policy Framework states that decision-takers may also give weight (unless material considerations indicate otherwise) to relevant policies in emerging plans according to:  the stage of preparation of the emerging plan (the more advanced the preparation, the greater the weight that may be given);  the extent to which there are unresolved objections to relevant policies (the less significant the unresolved objections, the greater the weight that may be given); and  the degree of consistency of the relevant policies in the emerging plan to the policies in this Framework (the closer the policies in the emerging plan to the policies in the Framework, the greater the weight that may be given). The Publication Draft Local Plan is considered to be at an advanced stage of preparation given that it is at the formal consultation stage prior to submission. Therefore it is considered that the policies, which have received no objection or significant comment relating to suggested changes, can be given weight in the determination of planning applications. The nature of the objections to the policies are referred to below so that an assessment of the weight to be given to each policy can be made. GP1 Achieving National Park Purpose and Sustainable Development Key parts of this Policy explain: 1. Sustainable development for Exmoor National Park will conserve and enhance the National Park, its natural beauty, wildlife and cultural heritage and its special qualities; promote opportunities for their understanding and enjoyment by the public, and in so doing, foster the social and economic wellbeing of local communities. 2. In achieving sustainable development all proposals for new development, activities and land use will demonstrate that: a) They are consistent with the National Park’s legal purposes and duty. Where there is irreconcilable conflict between the statutory purposes, the conservation and enhancement of the National Park will prevail consistent with the Sandford Principle; and b) They do not conflict with the vision and objectives of the Exmoor National Park Management Plan and the policies in this Local Plan read in combination. There has been a minor objection to this policy regarding modification to allow businesses to grow and develop.

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CE-S1 Landscape Character 1. The high quality, diverse and distinct landscapes and seascapes of Exmoor National Park will be conserved and enhanced. 2. Development should be informed by and complement the distinctive characteristics of the Landscape Character Types and areas identified in the Exmoor National Park Landscape Character Assessment (LCA). 3. Development proposals should also have regard to, and be appropriate in terms of impact with the conservation of significant landscape and seascape attributes. 4. Opportunities to conserve, enhance and restore important landscapes and landscape characteristics as identified in the LCA, including minimising existing visual detractions, will be encouraged. This Policy has received objections regarding the protection of the undeveloped coast, with improvements to cross-referencing to other policies suggested.

CE-D1 Protecting Exmoor’s Landscapes and Seascapes The key part of this policy explains; 1. Development will be permitted where it can be demonstrated that it is compatible with the conservation and enhancement of Exmoor’s landscapes and seascapes through ensuring that: a) the visual impact of the development in its immediate and wider setting is minimised through high quality design that reflects local landscape character with particular regard to scale, siting, materials, and colour; and b) the cumulative and/or sequential landscape and visual effects of development do not detract from the natural beauty of the National Park and the experience of tranquillity. This policy has been the subject of objection relating to modifications to improve cross- referencing for protection of the undeveloped/Heritage Coast and reference to the forthcoming seascape assessment.

AC-S4 Electricity and Communications Networks 1. Development to improve the accessibility and standard of the electricity and telecommunications networks will be encouraged in order to contribute to thriving communities and businesses, and climate change mitigation. Great weight will be given to ensuring that the National Park and its special qualities are conserved and enhanced. 2. Proposals will be supported where: a) the location, siting, scale and design of structures will not cause any unacceptable adverse impacts on the landscape and/or seascape character, visual amenity, biodiversity and cultural heritage of the National Park; b) co-operative working with partner organisations and utility operators has been demonstrated, to facilitate the sharing, utilisation and consolidation of existing communications infrastructure in rolling out new or improved communication technologies; and

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7.1 EXMOOR NATIONAL PARK AUTHORITY c) provision is made for the removal of apparatus and reinstatement of land when the apparatus becomes redundant. This Policy has been the subject of objections from National Grid and Western Power Distribution (WPD). The National Grid objection refers to consistency with National Policy Statement 1 and the National Planning Policy Framework where major development may be permitted in exceptional circumstances within National Parks. WPD consider that the policy should be amended to reflect their legal obligation to offer economic connections and operate an economic and efficient network.

Policy AC-D5 Radio and Mobile Telecommunications Infrastructure 1. Proposals for radio and mobile telecommunications development will be permitted where they first seek to share existing infrastructure, there is capacity in landscape terms, and no increase in height of existing masts is required. 2. Where it can be demonstrated that (1) is not possible, apparatus will be sited on existing masts or other features such as buildings or other structures, to minimise adverse effects on landscape character. 3. Where it can be demonstrated that (1) and (2) are not possible, the apparatus shall be sited and designed to ensure that it has an acceptable appearance in the landscape including through camouflage as a natural or traditional feature. 4. In determining all proposals: a) the highest standards of design will be sought in terms of colour, dimensions, construction and overall shape to minimise any visual impact; b) there will be no unacceptable cumulative or sequential visual impact with other vertical structures in the landscape; c) there will be no adverse effects on sensitive habitats and wildlife; d) if on a building, apparatus and associated structures should be sited and designed in order to seek to minimise impact to the external appearance of the host building; e) the amenity of nearby residents and visitors are not adversely affected; and f) opportunities for enhancement of the landscape including consolidation of any existing telecommunications infrastructure will be sought. 5. A condition will be attached to any planning consent to ensure that there will be ongoing management in place where trees are essential in providing amelioration to visual impacts including as camouflage to antenna within trees. This policy is supported by Historic England but the implications of such development should recognise the potential harm to the historic environment and cross reference policies elsewhere. A key material planning consideration is the advice from the National Planning Policy Framework. One of the key elements of the NPPF is achieving sustainable development. This is explained in paragraphs 7 and 8:

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7. There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:  an economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;  a social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and  an environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy. 8. These roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore, to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions. There is an emphasis on supporting a prosperous rural economy and supporting high quality communications infrastructure. There is also an emphasis on conserving and enhancing the natural environment. Paragraph 115 is the relevant section that refers to National Parks. This sets out that: Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty. The conservation of wildlife and cultural heritage are important considerations in all these areas, and should be given great weight in National Parks and the Broads. MAIN PLANNING CONSIDERATIONS Planning decisions needs to be taken in accordance with the policies of the Development Plan unless planning considerations indicate otherwise. The main planning considerations in this case are the impact of the mast in relation to the landscape of this section of the National Park, in particular whether the proposals, conserve and enhance the natural beauty, wildlife and cultural heritage of the area, and an assessment of the socio-economic benefits from the mast to the wider area in association with having regard to the specific policies in relation to mobile communications. Additionally there is a need to consider the relationship with the adjoining property Frogwell Lodge.

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Impact on Frogwell Lodge Looking first at the relationship to Frogwell Lodge. This property has a garden that extends west close to the proposed mast site, however, the house itself is approximately 150m to the east. The mast will be visible from the house, but given the distance and the intervening partial screen of trees, it is not considered that the mast would so affect the amenities of the residents of Frogwell Lodge that this could form a reason for refusal. Issues of the impacts on health have been raised. The NPPF, at paragraph 46, explains that Local Planning Authorities should not determine health safeguards if the proposal meets International Commission guidelines for public exposure. The applicant has confirmed that the mast will meet international safeguards. Frogwell Lodge is not connected to a mains electricity supply and the owner is keen that the proposals to provide a supply to the mast, if permitted, also benefit his property. The owner is in contact with Western Power to see what can be achieved and there is no planning reason why an electricity supply to Frogwell Lodge cannot be provided if the mast is also provided with a power supply. The mast application could not be refused if an arrangement regarding electricity supply cannot be reached; nevertheless it is hoped that progress can be made on this issue. A supply to Frogwell Lodge could be achieved without the need for a planning application. Landscape Impacts Haddon Hill is a ridge of prominent moor and woodland that runs east-west in the south east corner of Exmoor. The mast, if approved, would be sited in the corner of the car park. In terms of the visual impacts there are three main types of area where there is potential for a landscape impact and all these require careful consideration. These are, in and immediately surrounding the car park, in the wider area of Haddon Hill and from view points in the wider countryside. Under Standing Orders a pre-application briefing involving the Chairman of the then Planning Committee took place. The Chairman invited other Members to the site visit which involved the erection of a temporary 25m mast (rather than the 30m mast proposed as part of this application). This helped assess the landscape impact and photographs from that visit will be available as part of the Committee presentation. The visit took place in February 2015. Haddon Hill is popular with local residents and visitors and has extensive views to the north towards Wimbleball and Brompton Regis. Most of the views from the car park area are to the north because of the tree screen around the car park which screens views to the south. However, for those walkers that follow paths to the west, where the land rises, there are equally impressive views to the south over the open countryside. Within the car park, the mast will be very visible. At 30 metres in height the mast will be higher than the surrounding tree screen, which is approximately 15m to 20m in height. Within the car park there is low level screening, the trees will continue to grow and it would be possible to add to the screening within the car park with further planting. There is some built development in this immediate area such as the house, wind turbine, car park and information and toilet building. The mast is sited in this car park area, and will be seen in this context of this development but because of its scale, if permitted and constructed, it will be the most dominant built development.

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Immediately beyond the car park, especially in the area to the west and north of the car park the mast will be a clear and substantial feature. As walkers move north, down the slope towards Wimbleball the mast will eventually move out of sight because of the land form. If walkers follow the paths to the east, the woodland which is extensive and mature, will be between the mast and will provide screening. It is for walkers going to the west, where the land steadily rises towards the trig point, that the mast will be clearly seen above the trees and will be an alien feature in a predominantly natural scene. As visitors move further from the car park and the proposed mast, the wider landscape becomes more into view and because of the distance away from the mast it will become a less significant feature. The trig pint is approximately 700m from the proposed mast and is at 356m AOD. The top of the mast would be approximately 353m AOD. At this point the proposed mast would be at or just beyond the skyline, because of a belt of trees in the distance to the south-east. The Head of Conservation and Access has explained in her report, at Appendix 1, that at this point: “From the trig point at the top of Haddon Hill, the mast is visible and breaks the skyline, however, it forms only part of a panoramic view and the nearby trees create context for the vertical structure. On the southern slopes of Haddon (walking back from the trig point) the mast would dominate views and be in the direct line of sight of the viewer for some time. From this side of the hill the mast would have a damaging and negative impact on the quality of views and the perception of wildness.” It is also important to analyse the impact of the mast from areas wider than Haddon Hill. Again the Head of Conservation and Access and the Case Officer have looked at a variety of key sites. The main road from Haddon Hill drops down to the south and then rises up to another ridge. The mast would be clearly visible from this area to the south as it would be higher than the tree line. From this location outside the National Park the mast would have an impact but the views are expansive and the mast would not be a dominant feature and be partially screened by the existing trees. From other sites such as Upton Church, Bessom Bridge and Wimbleball car park, the views are from lower lying sites up towards Haddon Hill in the distance. The ridge line of the tree and moorland of Haddon is visible in expansive views and while it would be possible to see the mast above the tree line from these locations, given the distances involved it is considered that the landscape has the capacity to absorb this addition without material harm. Officers have questioned whether the mast could be reduced in height. The applicants have explained that reducing the mast height would reduce it effectiveness and the coverage that it would provide. By its very nature the mast does need be higher than the surrounding trees for it to operate.

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Alternative Options and Sites While each site needs to be considered on its own merits, and if the Haddon mast proposal is unacceptable or acceptable, having regard to all the planning issues, then the decision should be made accordingly. Nevertheless the applicants have looked at alternatives and these have been highlighted in the representations. In examining all matters it is considered helpful to look at these. Thirteen sites have been examined by the applicants. Many of these lie to the east of Wimbleball Lake where the land is lower lying. Even with a higher mast than at Haddon it would not provide the coverage that the present proposal would and it is likely that Brompton Regis would not be covered to the same extent. These masts would not provide coverage to the areas south of Haddon Hill (outside the National Park) that the present proposal would provide. These sites are also exposed in the wider landscape. Other sites have been examined on the south facing slopes of Haddon. These again would require a taller mast and not provide the coverage of the Haddon proposal, especially to the north within the National Park and also would not provide the same level of coverage for Brompton Regis. Before the application was submitted, Officers also looked at options for a mast on land to the west of Wimbleball Lake. While this area may have provided coverage to the Lake and Brompton Regis the wider area of coverage was not extensive and to provide greater coverage a much taller mast would be required with the related landscape impacts. These sites were discounted at an early stage. Officers have also examined whether it would be possible to add antennas to existing masts in the area to provide the necessary coverage. The area is not covered by the Brushford mast because of the intervening land form. To the south there is the Shillingford mast north of Bampton. This mast already provides mobile coverage to that area which does not extend to the north to cover the proposed area for the Haddon mast. There is the mast at Kennisham in the corner of the plantation adjoining the B3224. This mast measures approximately 36.5m in height and only accommodates Airwave equipment in relation to mobile networks. It would be possible to add antenna to this mast and this would cover a relatively wide area but would not extend to all of Brompton Regis and potentially would only cover part of Wimbleball. There is also the two masts at Brendon Hill near Roborough Gate Farm. These measure about 45m in height and again only accommodates the Airwave mobile equipment. Again one of these masts could accommodate antenna but again would only cover part of Wimbleball and not all of Brompton Regis. They could work in tandem but is judged that a mast to the south would still be required to provide the coverage for Brompton Regis and parts of the area not covered by these two masts. Under this analysis a mast at Haddon, or masts in the not spots that would remain, is judged to be required even if the other existing large masts are utilised. Another option is whether the area could be covered by a series of small masts that would meet the needs of each community. This would not be possible under the MIP and is unlikely to be a viable approach for the mobile companies because of the small population densities. Also it would mean that the mobile companies would be required to work independently and not in the coordinated way as at Haddon under the MIP. A series of

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7.1 EXMOOR NATIONAL PARK AUTHORITY small masts would have a landscape impact and there is the situation that commercially this is an option that the mobile companies are unlikely to pursue. With the rollout of superfast broadband there is the option of a providing backhaul via the broadband network rather than by micro-wave dish line of site to another mast. This again would be likely to utilise a small mast approach across the wider area. While technically this may be possible, this is presently not part of the Connecting Devon and Somerset Programme, the views of the mobile companies are unknown and importantly the small cells that come from smaller masts are less likely to provide the joined up coverage that a single larger cell would provide. A smaller cell structure would be satisfactory for a static user of a mobile phone but connection could be lost if someone was moving through the area. To conclude on this issue of alternative sites, Officers have examined as many options are possible to see whether there is another viable solution available that would provide coverage to this area. While it will always be possible to argue that another solution should be investigated, another technical approach evaluated or the reasons for dismissing a site are not convincing, given the information available Officers have come to the view that the present proposal is the most viable solution to provide coverage across this wider area. It should also be noted that no other proposal is before the Committee and that this present application needs to be considered on its merits. Planning Policy The planning policies are set out in detail earlier in this report. The overarching planning polices, LNC1 and GP1, in accordance with National Park purposes, requires that development should conserve and enhance the natural beauty, wildlife and cultural heritage of the area. The National Planning Policy Framework requires that this be given great weight in the decision making process. Within both the adopted Local Plan and the Emerging Local Plan there are a specific policies on telecommunications. Policy U11 of the adopted Plan sets a test, inter alia, that the telecommunication proposals will be permitted where there would be no unacceptable adverse effect on the natural beauty of the Exmoor Landscape. Policy SC-S4 of the Publication Version of the Local Plan uses a similar form of words and explains that telecommunication proposals will be supported, inter alia, when the location, siting, scale and design of structures will not cause any unacceptable adverse impacts. Policy AC-D5 seeks a sequential analysis of first looking at sharing existing masts, altering existing masts and buildings, and only then erecting new masts. Those new masts are required to be sited and designed to ensure that they have an acceptable appearance in the landscape. The telecommunications policies recognise that it is difficult to erect a new mast without some form of impact. For the antenna to work they must be clear of obstructions such as trees and therefore the structure will always need to be higher than the surrounding area. The test under these policies is not whether they cause an adverse impact but whether that adverse impact is unacceptable. Looking at the case with Haddon Hill and analysing purely the landscape impacts of the structure, in and around the car park and in the section of moorland to the west and north of the car park, it is considered that the mast, with its vertical and industrial form rising above the tree line, does cause landscape harm. It therefore fails the overarching policies requiring the conservation of natural beauty. Great weight needs to be given to this

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conclusion. In relation to the specific telecommunications policy it is clearly a judgment as to whether the adverse impact, its degree and extent, is an acceptable adverse impact in the particular circumstances of this case and therefore complies with these elements of the policies. Socio-Economic Impacts The mast is part of the Mobile Infrastructure Project. This is a Government sponsored initiative to provide mobile phone coverage to areas where there is no signal from any of the providers and the assumption is that it is economically unviable for the companies to invest in these areas. Without Government intervention it is unlikely that there would be coverage in the future. Importantly the Project requires all 4 phone companies to have their equipment on the mast. To date all the MIP masts have provided 4G coverage to their areas. 4G connectivity can be used as an alternative to broadband and allows much more than simply making and receiving phone calls. The applicants have submitted a proposed coverage plot of the area which would be covered if the mast was to be erected. This extends approximately 5km (3 miles) to the north, approximately 5km (3 miles) to the north-west and approximately 3km (1.8 miles) to the south. The villages of Skilgate, Upton and Brompton Regis would be covered by the proposed mobile coverage. The area would form a large single mobile phone cell which helps to ensure that reception is less likely to be lost when moving through the area. The majority of the area would fall within the National Park, and additionally land to the south beyond the Park boundary would also benefit. The coverage plan shows that the mobile phone signal would cover 63 Not Spots and 145 premises. Additionally the mast would provide mobile phone coverage for Wimbleball Lake, including its camp site, boating areas and footpaths. Wimbleball is a popular destination and also holds large scale sporting activities such as the annual Iron Man event. In past years there has been over 1,500 participants in each of the Iron Man events. The wider area is a base for a variety of businesses, including camp sites, farms, shoots, cafes and public houses. A local business based on equestrian activities has written to support the application because of the benefits to this business were the mobile phone coverage to be provided. The provision of mobile phone coverage to this section of the National Park is an important planning consideration. The applicants in their submissions, and detailed on page 3 of this report, explain the benefits that would be enabled including the ability to contact the emergency services, the socio-economic benefits to tourists, farmers, local trades persons, doctors, vets and others often on the move in rural areas. A secondary benefit is that there may be extended coverage to partial not spots, where there is perhaps one network but not the others. Connectivity is increasingly important in rural areas and this is summarised by Upton Parish Council who explain “we are a remote community and with poor internet connection the ability for more effective communications will be a huge boost to the area, its businesses and may even encourage further investment”. The need for improved mobile phone coverage is recognised in the National Park Management Plan under Priority C1. Good connectivity is increasingly important with many aspects of work and leisure which now often rely on being connected, for instance,

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farmers scanning livestock would benefit from being able to upload data directly via a mobile signal. To conclude on this issue, the area from Withiel Florey, south to Haddon Hill, including the village of Brompton Regis, has very poor, and usually no, mobile coverage. It the mast was to be built and coverage provided this would be an important boost to the local economy, and assist many residents and tourists. There would also be the safety benefits that coverage provides. Representations The representations received are important in helping to balance the weight to be given to the various planning considerations. The Exmoor Society and the CPRE raise strong objections regarding the adverse landscape impact in relation to this prominent, sensitive and popular location. They are clear in their view that the proposals fail the first National Park Purpose and related planning policies. These views are mirrored by the Head of Conservation and Access. Understandably these comments do not seek to make a detailed consideration in relation to the socio-economic benefits of the mobile coverage. This is a matter that will need to be taken into account by the Committee in coming to a decision on the application. Residents who have made representations believe that the mast will cause unacceptable harm and do not believe the benefits of coverage will outweigh that harm. One local business has written to support the application explaining the benefits that it will bring to his business. Brompton Regis Parish Council, Upton Parish Council and Skilgate Parish Meeting have all supported the application. They acknowledge the landscape impact; however, they judge that the mobile coverage for their areas is of such importance that they seek that permission is granted. Conclusions Haddon Hill is an open moorland landscape that is popular for both visitors and local residents. It lies on an elevated ridge with panoramic views across an expansive National Park landscape. The proposed mast with its antenna would be sited in the corner of the car park and, while partially screened, would dominate this immediate area. On the adjoining moorland, especially to the west and towards the trig point, the mast would be very apparent above the tree line. Further into the moorland, the mast would be seen in the wider context of the panoramic views and be less harmful. The mast would be mainly screened from views along the ridge to the east and because the land drops away to the north it eventually has less impact in this direction. In the wider landscape, such as from Wimbleball and Upton Church the mast would be visible but a smaller part of a wide landscape and where there is the capacity to accommodate this addition. In terms of landscape the mast with its antenna would be clearly visible from the areas of Haddon Hill surrounding the car park and in the areas up towards the trig point. On the basis that it is a tall, vertical and industrial form, the conclusion is reached that it does not conserve or enhance the natural beauty of the area. It is acknowledged that further from the car park the landscape is more expansive and as the land rises the mast is seen against a backdrop of trees in the further distance. Nevertheless, within the car park and areas immediately to the north and west, the conclusion is reached that the proposal fails

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7.1 EXMOOR NATIONAL PARK AUTHORITY the overarching planning policies for the protection of the natural beauty of the National Park. In terms of compliance with the specific telecommunication policies, there is a more balanced test recognising that infrastructure has to be visible for it to operate. Weight within the planning decision making process needs to be given to the socio- economic benefits that the mast will provide to those communities that presently have little or no mobile coverage. The area that the mast will cover is extensive in the Exmoor context and it is considered that the present application is the only one available for consideration. The decision for the Committee is to balance the various factors however, in deciding that balance it is necessary to give great weight to conserving landscape and scenic beauty. The Committee may judge, notwithstanding the importance of improved mobile connectivity, that the mast is simply too prominent because of its height and appearance in this popular and scenic location, and consequently there is conflict with the first National Park purpose and related planning policies. On this basis the application should be refused. This would accord with the views of the Exmoor Society and the CPRE. A reasons for refusal has been drafted at Appendix 2 of this report. On the other hand, the Committee, whist giving great weight to the first purpose and the need to conserve the landscape and scenic beauty of the area, and accepting that some harm is caused by the mast, may judge that as the mast is located in a car park with other built development, is partially screened from the moorland by trees, that the impact diminishes with distance and that the specific telecommunication policies may be met, that the benefits from mobile phone coverage to this wide Exmoor area are so significant that they outweigh any landscape harm that is caused. Consequently, on this basis, whilst giving great weight to landscape issues, the balance may fall in favour of approval on this occasion. This would accord with the views of the local Parish Councils. If the Committee is minded to approve then conditions are set out at Appendix 2. Recommendation The views of the Committee are sought.

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Appendix 1 Haddon Hill Proposed Telecommunications Mast, Prepared by Sarah Bryan, Head of Conservation and Access, 7 October 2015 This proposal is for a 30m telecommunications mast made up of a lattice tower set in a fenced enclosure in the south west corner of the Haddon Hill car park. Below, I have set out comments on the potential landscape and visual effects of the mast on Haddon Hill and the surrounding countryside. Policy matters are set out by the Head of Planning and Sustainable Development. Background I have known Haddon Hill for over 20 years and am familiar with the landscape and surrounding countryside. I visited the site on 16th Jan along with Members of the National Park Authority Planning Committee, specifically to look at the proposal for a 30m tower. The applicant had erected a 25m telescopic pole on the site to help inform the assessment of landscape and visual effects. Haddon Hill is an area of 176 hectares of open moorland, partly owned by the NPA (93ha). The moorland was purchased by Exmoor National Park Authority in 1980 in order to conserve and enhance the natural beauty and wildlife of the hill and to secure public access. The carpark was purchased separately in 1987 (from SWW). Haddon Hill is Open Access land and is very well used by the public. It is designated as Section 3 moorland and is also a Site of Special Scientific Interest and Special Area of Conservation. Haddon supports an important breeding bird community and a population of the nationally rare heath fritillary butterfly. The Haddon carpark has toilets, interpretation boards, a shelter and a grassy “picnic area” for visitor to the hill. Beech and birch trees are scattered across the grassy banks within the carpark. The carpark is relatively enclosed by scattered trees, but there are open views to the north towards Wimbleball reservoir. The proposed site for the mast is in the south west corner of Haddon carpark. To the west of the carpark is an area of former plantation which was largely clear felled in the early 2000’s in order to restore an area of heathland and provide south facing slopes for heath fritillary butterfly. A belt of pine was left along the southern fringe of the hill and adjacent to the carpark, in order to screen the carpark, provide some shelter and protect the neighbour’s trees from wind-throw. As anticipated, a number of these trees have been blown over in recent years. The longer term intention of the NPA has been to work with the neighbour to gradually remove this belt of trees and reveal the far reaching views to the south. To the south of the carpark is a small wind turbine (approximately 12m). Landscape Character Impacts Haddon forms part of the “Open Moorland” Landscape Character Type, key characteristics of which include;  Open, upland landscape defined by vast areas of heather and grass moorland with significant areas of bracken and gorse  A large scale landform of broad, gently undulating plateaux and rounded hills that loom over the adjacent low lying landscape

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 Highest areas offer long views across the varied landscape of the national park  Land use characterised by open rough grazing  Generally absence of settlement with the exception of individual farms. Minimal built development limited vehicle access or other visible human artefacts make for a tranquil landscape with some areas evoking a wild and remote character (Exmoor Landscape Character Assessment, 2007 p 61) Haddon is a relatively small area of Open Moorland, but is very accessible, offers elevated views and a sense of “wildness” in an otherwise more intensively farmed landscape. As such it is popular, particularly for local people. The open moorland character of the landscape means that it is highly sensitive to modern development, such as masts. While it is acknowledged that Haddon is not as remote, wild or sensitive as some of the larger tracts of Exmoor moorland, nonetheless it is an important and sensitive area of moorland in a national park. I consider that the proposed mast, by virtue of its size, verticality and industrial form does not conserve or enhance the character of Open Moorland. Visual Impact of the Proposed Mast In order to assess where the mast might be seen from, a map was drawn showing the Zone of Theoretical Visibility. This has been produced by a computer and takes into account landform but not hedgebanks, trees or other screening structures. Using this map, viewpoints were selected to assess visual effects. Viewpoint 1 Haddon Hill (carpark, trig point and surrounding moorland) The impact of the mast will be very significant in the carpark. As visitors arrive at Haddon the mast it will be directly in the line of view. The trees to the west provide some backdrop to the lower part of the structure but its height and industrial form mean that it will loom over the carpark and introduce a very obvious manmade and urbanising feature. The existing turbine means that there will be cumulative effects as both structures will be seen from the carpark From the trig point at the top of Haddon Hill, the mast is visible and breaks the skyline. However it forms only part of a panoramic view and the nearby trees create context for the vertical structure. On the southern slopes of Haddon (walking back from the trig point) the mast would dominate views and be in the direct line of sight of the viewer for some time. From this side of the hill the mast would have a damaging and negative impact on the quality of views and the perception of wildness. To the north of the carpark, looking north, there are far reaching views across the Brendon Hills. Turning back towards the carpark, the mast would appear as a very tall, vertical feature, dominating the view and at odds with the rural character of the landscape. Viewpoint 2 Road to South of Haddon Hill The road is enclosed by a hedgebank and occasional large trees. There are relatively few views of the mast and although the mast is skyline, from this viewpoint the mast would be partially camouflaged by surrounding conifers. Viewpoint 3 Upton Church This viewpoint was selected because there is a bridleway running to Upton Farm and the associated (redundant) church. The churchyard is a highly sensitive site, tranquil, remote

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and with a strong sense of the past. Views from here are sufficiently distant for the mast to be seen in the context of conifers along the ridge. It would be noticeable, but not dominant. Viewpoint 4 Bessom Bridge The mast would be visible above the trees but the distance mitigates the impact. This is a popular viewpoint, but while the mast would be visible I do not consider that it would have a damaging effect. Viewpoint 5 Wimbleball carpark and picnic area The mast is visible from the carpark and from the lakeside. The mast is associated with skyline tees and the distance means that while the impact is negative it is relatively minor. Summary of Visual Effects The mast would form a dominating and intrusive feature in the Haddon Hill carpark and would impact on the natural beauty of large areas of Section 3 moorland. Users of Haddon Hill visit the area both on foot and on horseback, to experience the wildness, the natural beauty and the far reaching views. The new structure and associated security fencing, by nature of their size, scale and industrial form, would have a damaging impact on the natural beauty and moorland character of the area. The impact of the mast would diminish with distance such that from more distant viewpoints such as Wimbleball Lake and Upton Church, the mast would be visible but would not dominate views or have a significant impact on enjoyment of the natural beauty of the landscape. Impacts on Special Qualities National Park Authorities are required to set out the “Special Qualities” of their National Park. Ten have been described for Exmoor including;  large areas of open moorland providing a sense of remoteness, wildness and tranquillity rare in southern Britain  a landscape that provides inspiration and enjoyment to visitors and residents alike  a timeless landscape, mostly free from intrusive development, with striking views inside and out of the National Park, and where the natural beauty of Exmoor and its dark skies can be appreciated From the carpark and Haddon Hill, the proposal would conflict with the conservation of these Special Qualities. Conclusions The proposed mast is a tall, industrial structure in a popular carpark and adjacent to an important area of Open Access, Section 3 moorland. People visit Haddon for its openness, views and sense of wildness. From the carpark itself and from large areas of Haddon Hill, the mast would appear as a dominant and alien feature which does not conserve or enhance the natural beauty of the National Park. It would appear at odds with the character of the landscape and would detract from the sense of wildness and naturalness of Haddon. The proposal would conflict with the conservation of a number of the Special Qualities of Exmoor. There are no opportunities to screen the mast from the most sensitive viewpoints on Haddon Hill. Some limited low level screening within the

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7.1 EXMOOR NATIONAL PARK AUTHORITY carpark by redesign of the layout and planting would be possible. This would mean changing the character of the carpark to a much more wooded site. The combination of distance and remaining conifers* along the ridge, ameliorate the visual impact of the mast in longer views from surrounding countryside. *The ENPA Woodland Officer has advised “the Scots pine are approaching their maximum height for the location and under ideal conditions will continue to mature and grow slowly for up to 50 years. Since the adjacent conifers were removed the remaining stand has become windfirm, however a catastrophic weather event could leave the trees subject to windthrow particularly in this exposed location. On these thin podsolic soils replacement conifer trees would take at least 30 - 40 years to provide limited screening on this exposed site.”

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Appendix 2

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Draft Reason for Refusal if the Committee is minded to refuse the application. The mast by reason of its size, verticality and industrial form, sited in this public and prominent location, does not conserve or enhance the character of the open moorland, would harm the visual amenities of the wider area at Haddon Hill detracting from the enjoyment of the public to this part of the National Park, fails the first National Park Purpose and as a consequence conflicts with Policies LNC1, CBS12, U11 of the Exmoor National Park Local Plan (2001-2011) and Policies GP1, CE-S1, CE-D1, CE-S6, AC-S4 and AC-D5 of the Publication Version Exmoor Local Plan (2001-2031). Draft conditions if the Committee is minded to permit the application. 1. The development hereby permitted shall be begun before the expiration of three years from the date of this permission. Reason - In accordance with the provisions of Section 91 of the Town and Country Planning Act 1990, (as amended by the Planning & Compulsory Purchase Act 2004). 2. The development hereby approved shall not be carried out except in complete accordance with the drawings submitted to the Local Planning Authority under this application, numbered 304282-00-004-ML001 Rev1, 304282-2—100-MD001 RevA, 304282-20-150-MD001 RevA and 304282-20-152-MD002 Rev2. Reason - For the avoidance of doubt and to ensure the development accords with the approved plans as amended. 3. No lighting shall be installed onsite without the prior permission, in writing, of the Local Planning Authority. Reason - To protect the amenities of this rural area and preserve Exmoor National Park’s designation as a Dark Sky Reserve. 4. All cables/wires to serve the development hereby permitted shall be placed underground unless otherwise agreed in writing by the Local Planning Authority. Reason - In the interests of the visual amenities of this part of the National Park. 5. The development hereby approved shall be removed from the site and the land reinstated to its former condition within 3 months of the equipment becoming redundant. Reason - In the interests of the visual amenities of this part of the National Park.

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Track

Track 323.0m

320.7m Def CB

D ef PC

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320.6m Wind Turbine 319.0m

Pond

Frogwell Lodge

0 Planning Application Site

Site Map Reproduced from an Ordnance Survey map with the permission of the 1:2500 Controller of HMSO © CrownCopyright reserved. Licence No 100024878

Planning Application No 6/30/15/101

Planning Application Site